2. Remember how the FDP FCOI Clearinghouse saved
pass-through entities and subrecipients from having
to swap written confirmations that we each had PHS-
compliant FCOI policies?
Now we welcome its big sister:
The FDP Expanded Clearinghouse!
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3. Goal of Expanded Clearinghouse
• Reduce administrative burden associated with
verifying standard information required for
subrecipient issuance and monitoring
• Eliminate swapping of subrecipient commitment
forms completed on a transaction-by-transaction
basis in favor of accessing an on-line, up-to-date
standardized, streamlined subrecipient data
repository
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4. Contents of Profile
• Organization Information
• Demographic Information (name, address, type, small
business status, parent information, etc.)
• Entity Identification Numbers and Codes
• Entity Rate Agreements
• Department of Defense Registration Numbers
• Department of Education Registration Numbers
• Assurances and Agency Approvals (Accreditations)
• DOD/ONR System Reviews
• Entity Key Contacts
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5. Contents of Profile (continued)
• Organization Certifications
• Conflict of Interest
• Debarment and Suspension
• Lobbying
• Affirmative Action Compliance
• FFATA
• Single Audit Information (will eventually also include
Financial Questionnaire option)
• Single Audit Status & Links
• Core info about any findings, deficiencies, material
weaknesses
• Organization Official Certification
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6. Core Elements of Expanded
Clearinghouse (EC)
• Organizations participate as both a subrecipient and as
a pass-through entity
• Participating organizations create their Profile in the EC,
and an authorized official certifies and submits it
• FDP EC administrators review, approve, and publish
each organization’s Profile
• PTEs access their participating subrecipients’ on-line
Organization Profile in lieu of sending a subrecipient
commitment form for each subaward between the
parties
• Transaction-specific information may still be shared
• Organizations update information in their Profiles as
needed
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7. At Time of Proposal
• Still acceptable & expected to collect from the
Subrecipient at time of proposal:
• Statement of Work
• Budget
• Any other forms needed for the proposal
• Small business plans, biosketches or other support,
certifications required at time of proposal, etc.
• Subrecipient’s proposal endorsement
• Signature of the Subrecipient’s SPA office and/or indication
they are willing to enter into a subaward if proposal is funded
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8. Process Changes to accommodate
When We are the Subrecipient:
• DO NOT COMPLETE a Subrecipient Commitment Form
for a pass-through entity participating in the Expanded
Clearinghouse
• Instead, please remind the other organization that we are a
participating Expanded Clearinghouse organization – see sample
language on the next slide
• Please be kind - remembering that many organizations are large
and decentralized – so it may take awhile for this updated process
to filter down to all parts of the organization.
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When We are the Pass-through Entity:
DO NOT COLLECT a Subrecipient Commitment Form
from another participating organization
9. Sample Language for Pushing Back if you are
asked to complete a Subrecipient Commitment
form by another participating organization
I am writing to let you know that [YOUR OWN INSTITUTION’S
NAME] is a Participating Organization in the FDP Expanded
Clearinghouse. It is my understanding that your organization is also
a Participating Organization. As a part of the FDP Expanded
Clearinghouse Initiative, both our organizations have agreed that
we will not send or require completion of subrecipient commitment
forms, but will instead use our profile that is posted on-line at the
FDP Expanded Clearinghouse site
(https://fdpclearinghouse.org/organizations).
Please use my profile to obtain the information you need. If you
have transaction-specific requirements, I will be happy to provide
those but I will need you to tell me precisely what you need via an
email or a transaction-specific request form (one that does not also
include data elements found in our profile.)
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10. At Time of Proposal or Award
• Okay to ask for or to complete a “transaction-
specific” request but only for data elements NOT
included on the organization profile, such as:
• Human subjects approval for that project
• Animal subjects approval for that project
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Getting pushback?
Talk to X or
Y (Subaward Team)
11. At Time of Award
• Departments should not collect or complete
subrecipient forms from participating organizations
(you shouldn’t either)
• At time of award, XXX (e.g. OSP, OG&C) will use the
EC to obtain the information needed to issue a
subaward or to do a risk assessment for
participating organizations
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12. Current Participating
Organizations
• To find the list of participating organizations (160+), go to:
https://fdpclearinghouse.org/
• Under “View the Organization Profiles,” click on:
• On right side of screen, search by organization name or
DUNS
• Check list frequently, as organizations are being added
one by one
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13. Next Steps
• An Application Programming Interface (API) is being
developed. This will enable organizations to
transfer data from the FDP Expanded
Clearinghouse into their own systems.
• Although most FDP members are Expanded
Clearinghouse participating organizations, some are
not. The goal is to involve all FDP members in the
EC.
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